Governance at IBM

Governance at IBM

IBM senior management is ultimately responsible for our economic, environmental, and social performance, as well as our adherence to IBM’s overall compliance programs. Corporate responsibility at IBM is integrated across the business through the following forums.

Corporate Responsibility Steering Committee

Our Corporate Responsibility Steering Committee comprises senior executives from functional areas across the business and is chaired by the vice president for Corporate Citizenship and Corporate Affairs. The committee meets periodically to provide leadership and direction on key corporate responsibility issues. Each functional area is responsible for the development of its own corporate responsibility goals and strategy, with organization-wide goals approved by the steering committee.

Corporate Responsibility Working Group

Our Corporate Responsibility Working Group consists of representatives from 10 functional areas (including global representation) and meets at least monthly to manage IBM’s corporate responsibility activities and stakeholder engagement across the company. The working group reviews key policy and strategic issues and makes recommendations to the steering committee throughout the year.

On a day-to-day basis, our activities are coordinated in the Corporate Citizenship and Corporate Affairs organization, which reports to the senior vice president for marketing and communications.

Stakeholder engagement

At IBM, we view stakeholder engagement as much more than communications and consultation. For us, it is about business engagement and collaboration—working shoulder-to-shoulder with communities, governments, investors, and the social sector.

Here are a few examples:

IBM also actively seeks to work with organizations that are taking similarly innovative, global, open, and collaborative approaches to corporate citizenship and sustainability. Our memberships include—but aren’t limited to—the following organizations that IBM is involved with and often serves as a leader. These organizations are also stakeholders who influence our corporate responsibility approach:

Academy of Business in Society

Admical

AmCham—Czech Republic CSR Committee

AmCham—Egypt CSR Committee

AmCham—Poland CSR Committee

American Chamber of Commerce in India—CSR Committee

American Malaysian Chamber of Commerce

Australian Sustainability Leaders Forum

Bundesnetzwerk Bürgerschaftliches Engagement

Business Civic Leadership Center

Business for Social Responsibility

Business for Society Platform

Business in the Community Ireland

Business in the Community UK

Canadian Council for Aboriginal Business (patron)

Carnegie Global Council

Center for Climate and Energy Solutions

Chilean United Way

Confederation of Indian Industry National Committee on CSR

Conference Board

Corporate Responsibility Group UK

Corporate Responsibility Officers Association

Council on Foundations

CSR Asia (IBM is a member of its Community Investment Round Table)

CSR Europe (IBM is the current chair)

CSR Sweden

CSR Turkey

Eco-Patent Commons

ECP—Platform voor InformatieSamenleving/Platform for Information Society

Electronic Industry Citizenship Coalition (IBM holds chair emeritus position)

Environmental Law Institute

European Academy of Business in Society (IBM is a board member)

Finnish Business Society

Fondazione Sodalitas

Forética

Fundación Seres

Grupo de Institutos, Fundações e Empresas

Grupo de Reflexão e Apoio à Cidadania Empresarial

Instituto Argentino de Responsabilidad Social Empresaria

Institute for Supply Management

International Electronics Manufacturing Initiative

Jet-Net

JINC

Kauri

Leaders for Nature IUCN

Lime Connect

Maala

MVO Nederland

NASSCOM Foundation, India

National Council of Voluntary Organizations

Ozel Sektör Gönüllüleri Dernegi / Corporate Volunteers Association

Points of Light Institute Corporate Council

respACT

South Africa United Way

US Chamber Foundation Center for Corporate Citizenship

Universciences Partenaires

VHTO—Dutch National Expert Organization on Girls/Women and Science/Technology

Wirtschaft für Integration

Wirtschaft. Initiative. Engagement.

World Environment Center

World Wildlife Fund Climate Savers Program

Codes of Conduct and Ethics Training

IBM’s Business Conduct Guidelines (BCG), including the Government Client Guidelines supplement, reflect our longstanding commitment to ethical conduct and decision-making. Serving as our global code of conduct for IBM employees everywhere we do business, the BCG is available in 25 languages and is deployed in 106 countries. Each year, IBM employees are required to certify to the BCG and complete online, interactive training. The BCG course is refreshed annually to include timely and relevant business scenarios that employees may face when conducting IBM’s business. The BCG course is available in 14 languages.

In addition to the global online BCG training, on an ongoing basis, IBM Trust and Compliance Officers, IBM lawyers, and management provide compliance and ethics training to employees around the world in targeted group sessions. IBM also provides targeted ethics training across the organization, including managers and non-managers across business units and internal functions. New employees—whether joining IBM individually or through acquisitions—are required to complete the BCG course and receive new employee orientation that includes compliance and ethics content. Sales and marketing employees from newly acquired companies also receive live, mandatory ethics training shortly after the close of an acquisition.

IBM’s culture of ethics and integrity is strengthened by its business leaders’ unwavering emphasis on these principles in their communications to employees. From country general managers to business unit leaders, IBM management sets the tone for the vital importance of ethical and lawful conduct. IBM’s local business leaders hold events and meetings with employees that contain a series of discussions and workshops on integrity-related topics.

Working with third parties continues to be an integral part of IBM’s business in meeting the needs of our clients. IBM’s Business Partner Code of Conduct and the Electronic Industry Citizenship Code of Conduct describe the standards of business conduct and practices we expect from our business partners and suppliers. As appropriate, IBM provides business partners and suppliers with online education on ethics and integrity, and also conducts live ethics and integrity training of business partners and suppliers in many instances.

IBM provides communications channels for employees, suppliers, business partners, and others to report concerns or suspected violations to the company, including ways for submitting anonymous reports. IBM does not tolerate threats or acts of retaliation against any employee for reporting a concern or suspected violation.